The United States v. Vogel Fertilizer Co., 1981, was a case that revolved around the interpretation of tax law and its application to corporations with multiple shareholders. The Internal Revenue Service (IRS) argued that Vogel Fertilizer Company, which had two shareholders - one owning 51% and the other owning 49%, should be considered as a "personal holding company" under Section 542(a) of the Internal Revenue Code. This would subject it to additional taxes on undistributed income. However, Vogel contended that they did not meet this definition because more than half of their stock wasn't owned by five or fewer individuals during the last half of each taxable year in question as required by Section 544(a)(7). The Supreme Court ruled in favor of Vogel Fertilizer Co., stating that for purposes of determining personal holding company status, stock ownership must be calculated according to voting power rather than value; thus exempting them from being classified as a personal holding company since only one individual had majority voting power.

The dissenting opinion in the United States v. Vogel Fertilizer Co. case argued that the majority's interpretation of Section 1563(a) of the Internal Revenue Code was incorrect and inconsistent with Congress' intent when it enacted this provision. The dissenters believed that a corporation should be considered as owning its own stock if it has voting power over such stock, even if another entity technically holds legal title to it. They contended that this approach would better serve to prevent tax evasion by large corporations who might otherwise use complex ownership structures to avoid being classified as "brother-sister" controlled groups under Section 1563(a). Furthermore, they disagreed with the majority's reliance on legislative history, arguing instead for an interpretation based solely on statutory text and structure.